COOKIE POLICY OF SIROKO TV
1. General information about the use of cookies
1.1. What are cookies
Cookies are small text files that websites and applications download onto the user’s device (computer, smartphone, tablet, smart TV or other device) when the user accesses them. They allow the website or application to recognise the device, remember user preferences, facilitate navigation and, in certain cases, analyse user behaviour or display personalised advertising.
In addition to cookies in the strict sense, there are other similar technologies, such as pixels, tags, web beacons, device identifiers and local storage technologies (localStorage and sessionStorage). For the purposes of this Policy, all such technologies are collectively referred to as “cookies”, in accordance with the broad interpretation adopted by the Spanish Data Protection Agency (Agencia Española de Protección de Datos).
1.2. Where cookies are stored
Cookies are stored on the user’s own device, within the browser or operating system memory. They may then be accessed by the website or application that placed them (first-party cookies) or, where applicable, by third-party websites or services (third-party cookies).
1.3. Types of cookies
A) Based on their purpose
- Technical cookies. They allow navigation and the correct functioning of the site or application. They manage the session, traffic, user identification, access to restricted areas, form recall, payment management, fraud security, video and audio playback, and other essential functionalities.
- Personalization or preference cookies. They remember information that personalizes the user’s experience, such as language, content layout, region accessed from, or preferred viewing format.
- Analytics cookies. They allow the number of users to be measured, user interaction with the service to be analysed and statistical data to be generated to improve the Platform.
- Advertising cookies. They allow to manage the advertising space of the site or application and to show personalized ads based on the user’s behavior.
B) Based on the entity managing them
- First-party cookies. They are sent to the user’s device from a computer or domain managed directly by Siroko Solutions, S.L.
- Third-party cookies. They are sent to the user’s device from a computer or domain managed by a third party that processes the information obtained through cookies.
C) Based on their storage period
- Session cookies. They collect and store data while the user accesses the service and are deleted at the end of the session.
- Persistent cookies. The data remains stored on the device for a certain period of time, set by the cookie manager.
2. Applicable regulatory framework
The use of cookies on Siroko TV is subject, in particular, to the following rules:
- Article 22.2 of Spanish Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce (LSSI-CE), which requires users’ informed consent for the storage and retrieval of information on their terminal devices, except for strictly necessary cookies.
- Regulation (EU) 2016/679 (GDPR), particularly Articles 6 and 7 thereof.
- Spanish Organic Law 3/2018, of 5 December, on Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).
- Guidance on the use of cookies from the Spanish Data Protection Agency, in its current version of July 2023.
3. Cookies used by Siroko TV
Siroko TV uses first-party and third-party cookies for the purposes described in section 1.3. The full and updated list of cookies currently in use, including the identity of the provider, their purpose, legal basis and retention period, is contained in Annex I.
Consent management tool. Siroko TV uses a Consent Management Platform (CMP), such as OneTrust, Cookiebot, Didomi, CookieFirst, a proprietary solution, or a similar provider, which allows users to accept, reject, or manage cookie preferences at any time and keeps a record of the choices made.
4. How Siroko TV requests consent
Upon the user’s first access to the Platform, Siroko TV displays a cookie banner describing, in a clear and concise manner, the purposes of the different categories of cookies used and the options available.
In accordance with the guidelines issued by the Spanish Data Protection Agency, the banner provides three options with the same level of visibility and accessibility:
- Accept all cookies. Authorizes the installation of all categories described in this Policy.
- Reject all cookies. Rejects the installation of non-essential cookie categories. Strictly necessary technical cookies will remain enabled.
- Cookie settings. Allows the user to individually select which categories to accept or reject.
Withholding consent will not limit access to the Platform’s essential functionalities. Siroko TV does not use cookie walls or condition access to the Platform on the acceptance of non-essential cookies.
Renewal of consent. In accordance with the AEPD Guidelines of July 2023, Siroko TV will request the renewal of consent every twenty-four (24) months from the user’s last expression of consent, as well as whenever significant changes are made to the purposes of processing or to the cookies used.
Proof of consent. In accordance with Article 7.1 RGPD, Siroko TV keeps a technical record of the consent given by each user, indicating the categories accepted, date, time and version of the banner.
5. Management and withdrawal of consent
Users may modify or withdraw their consent at any time, without affecting the lawfulness of any prior processing. For this purpose, Siroko TV provides:
- Cookie preferences panel. Permanently accessible from the footer of the Platform.
- Browser configuration. Links to official instructions of the main browsers:
- Google Chrome: https://support.google.com/chrome/answer/95647
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop
- Apple Safari: https://support.apple.com/en-euro/guide/safari/sfri11471/mac
- Microsoft Edge: https://support.microsoft.com/en-US/edge/manage-cookies-in-microsoft-edge-view-allow-block-delete-and-use
- Opera: https://help.opera.com/en/latest/web-preferences/#cookies
- Brave: https://brave.com/privacy/browser/
5.1. Private mode
Many browsers offer a private or incognito mode that automatically deletes cookies after your visit, ensuring that the pages you visit are not recorded in your browsing history. This mode may limit the functionality of the Platform and is not a substitute for active consent management.
6. Siroko TV responsibilities
Siroko Solutions, S.L. undertakes to provide users with clear, complete and accessible information regarding the use of cookies, as well as effective tools for managing their consent.
In addition, it adopts the necessary technical and organisational measures to ensure the security of the information obtained through cookies and the secure preservation of proof of consent.
7. Modifications
Siroko Solutions, S.L. may amend this Policy whenever required by regulatory changes, new technologies, the incorporation of new providers or changes to the purposes of processing. Substantial changes will be communicated to the user through the banner with a request for renewal of consent.
8. Associated legal documents
This Policy is supplemented, in all matters not expressly regulated herein, by:
- Legal Notice.
- Terms and Conditions of Use.
- Privacy Policy.
9. Contact
- Siroko Solutions, S.L., Plaza 6 de Agosto nº 6, 2º, 33203 Gijón (Asturias), Spain.
- E-mail: gdpr@siroko.com
- Data Protection Officer: Martín López Escartiín, gdpr@siroko.com.
ANNEX I. List of cookies
This Annex lists the cookies that Siroko TV places on the user’s device, differentiating between first-party and third-party cookies.
A) First-party cookies
| Cookie | Type | Purpose | Storage period |
|---|---|---|---|
| sirokotv_session | First-party technical cookie | Management of the user’s session during browsing. | 1 day |
| XSRF-TOKEN | First-party technical cookie | Site security; prevention of cross-site request forgery (CSRF) attacks. | 1 day |
| sirokotv_auth | First-party technical cookie | Identification of authenticated registered users. | 1 year |
| lang | First-party preference cookie | Displaying the content of the Platform in the language preferred by the user. | 1 year |
| theatermode | First-party preference cookie | Remembering the user’s selected display mode in the video player. | 1 year |
| guest_id | First-party preference cookie | Improving the experience of unregistered guest users. | 1 year |
| url_type / url_type_id | First-party preference cookie | Tracking the type of content from which the user initiates the registration process. | 1 year |
| cproll | First-party advertising cookie | Video ad management. | 30 minutes |
Siroko Solutions, S.L. · Tax ID No. B33950338 · Plaza 6 de Agosto nº 6, 2º · 33203 Gijón (Asturias), Spain · gdpr@siroko.com